Inherited IRA Year-of-Death RMD: What Beneficiaries Must Do

If the person who left you their IRA died partway through the year without taking their full required minimum distribution, that shortfall doesn't disappear — it becomes your obligation. Here's exactly what that means, how to calculate it, and when it must be done.

Does the year-of-death RMD apply to your situation?

This obligation only applies when two conditions are both true:

1. The original IRA owner died on or after their Required Beginning Date (RBD) — meaning they had already been required to take RMDs during their lifetime.
2. They had not yet taken the full RMD for the year in which they died.

If the owner died before their RBD — for example, a parent who died at age 68, before reaching the RMD threshold — there is no year-of-death RMD. No distribution was owed in the year of death, so nothing carries over to the beneficiary.

What is the Required Beginning Date?

The RBD is the date by which the original owner was required to begin their own lifetime distributions:²

• Born 1951–1959: RBD is April 1 of the year after they turned 73
• Born 1960 or later: RBD is April 1 of the year after they turned 75
• Born 1950 or earlier: RBD was April 1 of the year after they turned 72 (prior-law cohort)

Someone born in 1953 who died in November 2026 turned 73 in 2026 — so their RBD was April 1, 2027. Because they died before reaching their RBD, no year-of-death RMD applies. But a sibling also born in 1953 who died in November 2027 died after their April 1, 2027 RBD — so the year-of-death RMD does apply for that 2027 tax year.

How to calculate the year-of-death RMD

The calculation uses the decedent's own RMD formula — the same calculation they would have completed had they lived through the year.

Step 1: Find the prior December 31 account balance

Use the IRA balance as of December 31 of the year before the year of death. This is the balance the custodian uses for RMD purposes, not the balance at the date of death.

Example: The owner died in March 2026. Use the IRA balance as of December 31, 2025.

Step 2: Find the decedent's distribution period

Look up the distribution period from the Uniform Lifetime Table (IRS Publication 590-B, Appendix B, Table III)³ using the age the decedent would have turned in the year of death — their age on December 31 of that year, whether or not they lived to that birthday.

Exception: if the decedent's sole beneficiary was a spouse more than 10 years younger, they could have used the Joint and Last Survivor Table (IRS Pub. 590-B, Table II) instead. Use whichever table the decedent was entitled to use.

Step 3: Subtract any distributions already taken

If the decedent had already taken any IRA distributions in the year of death before they died, those count toward the year-of-death RMD. Subtract that amount from the required amount.

Deadline: December 31 of the year of death

The year-of-death RMD must be taken by December 31 of the same calendar year the owner died. There is no extension and no 60-day rollover window — this is a required distribution, not an elective one.

In practice, the custodian will often pay out the year-of-death RMD automatically as part of the inherited IRA transfer process. But many custodians don't — they leave it to the beneficiary to request it. If no one asks the custodian, no distribution happens.

When you're going through the account transfer process, always ask the custodian explicitly: "Was the full RMD for the year of death already taken?" If not, request a distribution of the remaining amount before year-end. This is one of the first questions to resolve when opening an inherited IRA.

Multiple beneficiaries: how the obligation is shared

When multiple people share the same inherited IRA, the year-of-death RMD obligation is divided among them in proportion to their percentage interest in the account. Each beneficiary must take their allocated share by December 31 of the year of death.

Note: the year-of-death RMD must be taken before the beneficiaries can establish separate accounts and begin their own independent 10-year windows.

What if the year-of-death RMD was missed?

Missing the December 31 deadline triggers a 25% excise tax on the undistributed amount (IRC § 4974). Under SECURE 2.0 (§ 302), the penalty drops to 10% if you file an amended return and correct the shortfall within a 2-year correction window.⁴

The IRS waived penalties for missed inherited IRA annual RMDs from 2021 through 2024 under Notices 2022-53, 2023-54, and 2024-35. Those waivers did not cover year-of-death RMDs — they applied only to the annual distributions required during the 10-year window for beneficiaries of post-RBD decedents. A missed year-of-death RMD was, and remains, subject to the standard penalty.

For a step-by-step correction process — calculating the shortfall, filing Form 5329 Part IX, and writing a reasonable-cause waiver letter — see: Missed Inherited IRA RMD: How to Correct and Reduce the Penalty.

How the year-of-death RMD interacts with the 10-year rule

The year-of-death RMD and the 10-year depletion rule are two entirely separate obligations on two separate timelines:

• The year-of-death RMD is due by December 31 of the year the owner died — it is not part of the 10-year window at all.
• The 10-year clock starts the year after the year of death. Year 10 ends December 31 of the 10th year following the year of death.

Example: Owner died in June 2025. The year-of-death RMD is due by December 31, 2025. The 10-year window runs from 2026 through December 31, 2035. The two obligations don't overlap — the year-of-death RMD is a 2025 responsibility, and the 10-year window begins in 2026.

It's also worth noting: if the decedent was in Group B (died after RBD), you will owe annual RMDs during the 10-year window on top of the year-of-death RMD. These are different calculations using different tables. The year-of-death RMD uses the decedent's own Uniform Lifetime Table factor. Your annual inherited-IRA RMDs use your age from the Single Life Expectancy Table, starting the year after death. See the full mechanics: Inherited IRA RMD Rules — annual calculation during the 10-year window.

Roth IRAs and 401(k)s

Inherited Roth IRAs: No year-of-death RMD applies. Roth IRA owners are never required to take lifetime distributions (IRC § 408A(c)(5)). Without a lifetime RMD obligation, there is no year-of-death undistributed amount to carry over to beneficiaries. See: Inherited Roth IRA Rules.

Inherited 401(k)s and other qualified plans: The same year-of-death RMD logic applies to employer plans. If a 401(k) participant died after their RBD with an incomplete RMD, the remaining amount must be distributed from the plan by December 31. If you then roll the account to an inherited IRA via direct trustee-to-trustee transfer (IRC § 402(c)(11)), the rollover covers the post-RMD balance only — the year-of-death RMD portion must be distributed first, not rolled over. See: Inherited 401(k) Rollover Guide.

Why this is easy to miss — and costly to ignore

Most people who inherit an IRA focus immediately on the 10-year depletion window. The year-of-death RMD obligation is less well-known, frequently skipped by custodians, and sometimes not flagged by the estate attorney or accountant. It's a small amount relative to the account — but the 25% excise tax on a missed $15,000 distribution is $3,750, before any late-filing interest.

The fix is simple if you catch it early: ask the custodian in the same conversation where you set up the inherited IRA account. "Was the year-of-death RMD fully distributed?" If no — or if they don't know — request the distribution before December 31.

Sources

1. IRC § 401(a)(9)(B)(i): if the IRA owner dies after the required beginning date, distributions must be made at least as rapidly as under the method in effect at death. IRS Reg. § 1.401(a)(9)-5(c): the year-of-death RMD must be distributed by December 31 of the calendar year of death. IRS — RMDs for IRA Beneficiaries.
2. SECURE 2.0 Act of 2022, § 107 (amending IRC § 401(a)(9)(C)): Required Beginning Date is April 1 of the year following the year the owner turns 73 (born 1951–1959) or 75 (born 1960 or later). IRS — Retirement Topics: RMDs.
3. IRS Publication 590-B (2025 edition), Appendix B, Table III: Uniform Lifetime Table for calculating the decedent's own year-of-death RMD. Account balance used is December 31 of the prior year; age used is the age the owner would have reached in the year of death. IRS Publication 590-B.
4. IRC § 4974 (excise tax on excess accumulations): 25% excise tax on the amount by which the RMD exceeds actual distributions for the year. SECURE 2.0 Act of 2022, § 302: penalty reduced to 10% if the shortfall is corrected within a 2-year correction window. IRS — Correcting RMD Failures.
5. IRS T.D. 10001 (July 18, 2024): final regulations on required minimum distributions under IRC § 401(a)(9), including confirmation of the annual RMD requirement during the 10-year inherited IRA window when the decedent died on or after their Required Beginning Date. Year-of-death RMD rules are in Reg. § 1.401(a)(9)-5(c). T.D. 10001 — Federal Register.

Rules verified against 2026 IRS guidance. Uniform Lifetime Table updated per T.D. 9930 (effective 2022) — values in IRS Publication 590-B. SECURE 2.0 penalty rates effective January 1, 2023. IRS Notices 2022-53, 2023-54, and 2024-35 waived annual inherited-IRA distribution penalties for 2021–2024 only; year-of-death RMD penalties were not waived.